Draft White Paper 

REVIEW OF NEW SURROGATE DATA FOR ESTIMATING INTAKES 

OF URANIUM AT GENERAL STEEL INDUSTRIES 

Contract Number 200-2009-28555 

Prepared by 

Robert Anigstein, William C. Thurber, and Harry J. Chmelynski 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

November 25, 2012 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board 

on Radiation and Worker Health (ABRWH) to maintain all possible openness in its 

deliberations. However, the ABRWH and its contractor, SC&A, caution the reader that at the 

time of its release, this report is pre-decisional and has not been reviewed by the Board for 

factual accuracy or applicability within the requirements of 42 CFR 82. This implies that once 

reviewed by the ABRWH, the Board’s position may differ from the report’s conclusions. Thus, 

the reader should be cautioned that this report is for information only and that premature 

interpretations regarding its conclusions are unwarranted.
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Document Description: 

White Paper: Review of New 

Surrogate Data for Estimating 

Intakes of Uranium at General 

Steel Industries 

Effective Date: 

Draft – November 25, 2012 

S. Cohen & Associates:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program 

Revision No. 0 (Draft) 

REVIEW OF NEW SURROGATE DATA FOR 

ESTIMATING INTAKES OF URANIUM AT 

GENERAL STEEL INDUSTRIES 

Page 2 of 18 

Task Manager: 

 ____________________________ Date:__________ 

 Robert Anigstein, PhD 

Supersedes: 

N/A 

Project Manager: 

 ____________________________ Date:__________ 

 John Stiver, MS, CHP 

Reviewer: 

 John Mauro, PhD, CHP 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 11/25/12 Initial issue 
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Review of New Surrogate Data for Estimating Intakes of Uranium 

at General Steel Industries

1 Introduction 

During Meeting 84 of the Advisory Board on Radiation and Worker Health on June 20, 2012, the 

Board tasked SC&A with reviewing NIOSH’s use of surrogate data for estimating intakes of 

uranium at General Steel Industries (GSI). In fulfilling that task, Anigstein (2012) reviewed the 

surrogate data used by Allen and Glover (2007) and found that these data did not satisfy the 

Board’s five criteria for the use of such data (ABRWH 2010). In response, Allen (2012a) 

reviewed measurements of airborne uranium activity concentrations at three additional work 

sites and concluded the original data used by Allen and Glover constituted a plausible upper 

bound. Both reports were discussed at the August 28, 2012, meeting of the ABRWH Work 

Group on TBD-6000. At the conclusion of the meeting, the work group requested that NIOSH 

look for surrogate data from sites that have handled the same types of uranium as GSI. 

Allen (2012b) stated that “NIOSH broadened its search for data related to the handling of cold 

uranium metal.” In this report, which was issued November 6, 2012, he reviewed additional 

measurements of airborne uranium activity concentrations. He compiled a list of 37 actual or 

implied measurements for seven individual operations at various work sites to use as a surrogate 

for uranium concentrations during uranium handling at GSI. He evaluated the use of these data 

against the Board’s five surrogate data criteria and concluded that they satisfied the criteria. He 

then derived a value of 104 dpm/m3

 as the upper 95th percentile of these data, assuming they 

constituted a lognormal distribution, and assigned this value to the bounding airborne uranium 

concentration during uranium handling operations at GSI. 

2 Definition of Cold Uranium Metal 

Allen (2012b) defined cold uranium metal as metal that has not been physically heated. In fact, 

all uranium metal has been heated at some point in its metallurgical history. We presume that 

Allen was referring to intermediate or finished uranium mill products that had undergone some 

surface conditioning after high temperature processing to remove loose surface scale. For 

example, uranium slugs have a machined surface. Uranium ingots are produced by vacuum 

melting of derbies and therefore should have little oxide scale. Any dross resulting from the 

melting process would rise to the top of the melt and be subsequently removed when the cast 

ingot was cropped. The betatron slices produced at Mallinckrodt were sawed from these ingots 

(Westbrook and Bloom 2007). The sawed surfaces of the slices would tend to tarnish in air. The 

resulting thin oxide film prevents further oxidation of the bulk metal at room temperature (DOE 

2001). The cylindrical surfaces would be those of the vacuum-cast ingots. Dingots would 

presumably have an oxidized surface resulting from the bomb reduction process. However, it is 

likely that most loosely adherent oxide would be removed during surface cleanup with a 

pneumatic chipping hammer (Westbrook and Bloom). It is also possible that aggressive 

handling of uranium metal shapes could actually abrade the metal causing particles to oxidize 

and become airborne. However, uranium metal is quite ductile, so the amount of material 

produced should be small. 
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3 Review of Airborne Uranium Activity Concentrations 

In order to review Allen’s (2012b) distribution of uranium activity concentrations, we performed 

an independent analysis of the data. We reviewed the seven source documents cited in his report 

and selected the data that, in our judgement, were most suitable for constructing a distribution to 

be used to derive a surrogate for uranium concentrations at GSI. We also reviewed other 

references pertaining to these work sites in order to gather more information about the processes 

that gave rise to these concentrations. Our evaluation of the data for each site is discussed 

below. The results of our analysis are presented in Table 1, which appears after the reviews of 

the source documents. 

3.1 R. K. LeBlond Machine Tool Company 

As described by Allen (2012a), 

A test was conducted at Leblond [sic] to evaluate a hole boring machine. Air 

samples were taken while boring a hole into a uranium billet with a rapid bore 

machine. Coolant was used while boring the hole but air samples were taken 

while loading the dry billet onto the machine. . . . The remarks section of the data 

sheet indicates there was no ventilation on the machine and very little air 

movement. Coolant used during the boring reduced any possible interference 

from nearby operations. Together, these issues make the Lebland [sic] samples 

the most directly relevant samples to the work at GSI. 

Allen (2012b) included six of the breathing zone (BZ) samples measured at LeBlond in his data 

set. The first three were described as “operator hooking hoist to billet and placing billet into 

position on machine,” while the next three were “operator removing billet from machine after 

billet had been bored and placing billet on scale” (Workum 1961). We agree that these 

measurements were appropriately included in the surrogate data set. However, we believe that 

six other samples should be included. These are described as “Operator operating controls of 

machine. No visible dust or fumes – oil splatters near end of operation.” (Workum 1961) 

Although these samples were taken during the boring operation, the boring was performed under 

a continuous flow of liquid coolant that washed the chips down a pipe to the coolant tank. This 

prevented any significant contribution of material removed from the billet by the drill bit to the 

airborne activity. This second set of measurements produced values in the same range—”nd” to 

15 dpm/m3

—as the first set; including these measurements doubles the number of data points for 

this facility. 

3.2 Chambersburg Engineering Co. 

According to Allen (2012a), 

At Chambersburg Engineering approximately 150 hot uranium slugs were forged 

into washers during a two day test. The slugs were dry heated and no ventilation 

was provided for the work. . . . The average air concentration while loading cold 

uranium slugs into a furnace was 69 dpm/m3

 while loading one slug every 15 

minutes and increased to 77 while loading one slug every two minutes. The 

maximum air concentration while loading cold uranium into the furnace was 
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174 dpm/m3. Air concentrations after heating and while forging were higher and 

it is possible some of that airborne contamination caused by this work interfered 

with samples taken while loading the furnace. 

Rube (1957) included a summary of measurements of 19 BZ samples collected at seven 

individual locations during this operation. The highest concentrations—from 314 to 1268 

dpm/m3—were measured in the BZ of the impactor operator controlling the impactor at a 10-ft 

distance. As Rube reported, “The major portion of the dust generated from these operations 

drifted north toward the impactor control panel where the impactor operator stood while 

stamping the washers.” Although Allen (2012a) cited this reference and reproduced the data in 

his Figure 3, Allen (2012b) selected three samples from NLO 1957 that lists a subset of the data 

cited by Rube. These samples were collected at 5-min intervals in the BZ of the “operator 

working safety control on impactor, which is located 5′ west of impactor.” They had a range of 

5–28 dpm/m3. 

We do not believe that the Chambersburg measurements should be included in the surrogate data 

set since, contrary to Allen’s (2012b) statement that NIOSH “broadened its search for data 

related to the handling of cold uranium metal [italics ours],” the uranium was hot during the 

forging operation. The operator working the safety control, whose readings were included in 

Allen’s data set, was only 5 ft from the machine, while the operator at the control panel, whose 

readings were excluded, was 10 ft away. Since these samples were collected during the hot 

forging operation, as were the rest of the samples at this facility, there is no basis for selecting 

them for the surrogate data set in preference to other samples which had higher readings. 

3.3 Tocco Induction Heating Division, Cleveland 

According to EECAP (2012), 

Tocco Induction Heating in Cleveland, Ohio had a contract with National Lead of 

Ohio (Fernald) to develop induction heating coil equipment for heating uranium 

fuel cores. Tocco performed operational tests of these units at its Cleveland Ohio 

facility, which took place during 1967-1968. The company received 2000 

pounds of natural uranium machined fuel cores and 5600 pounds of depleted 

uranium machined fuel cores from NLO for testing. 

NLO (1968) provided data on air samples collected at Tocco on February 16 and June 6, 1968. 

The February data were from “8′′ normal slugs – no ventilation” and include two BZ samples, 

described as “loading uranium slugs on run in table,” that Allen (2012b) properly included in the 

surrogate data set. There were four additional samples, collected slightly later the same morning, 

for “8′′ normal slugs – no ventilation, smoke and or fumes could be seen when the slug hit the oil 

bath.” These samples, with measurements that ranged from 12 to 113 dpm/m3

, were described as 

“working controls west of the oil bath.” Allen appropriately excluded them from the data set. 

The June data were from “normal & depleted slugs being heat treated.” These data include 12 

BZ samples. The time sequence of the sampling casts additional light on the processes that took 

place. Three samples “loading slugs at loading tray – heating,” were collected between 10:26 

and 10:28 o’clock; three “loading slugs – no heat,” were collected at 11:15–11:17. Six samples 
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were from “unloading slugs from conveyor and putting in box,” three of which were collected at 

11:45–11:50 and the rest at 1:05–1:09. Allen (2012b) included the first six samples, which 

ranged from “nd” to 37 dpm/m3

, in the surrogate data set, but excluded the last six, with 

measurements of 59–320 dpm/m3

. Given the time sequence and the measured values, it is most 

likely that these latter measurements were made after the uranium was heated, and were thus 

properly excluded. 

We agree that the measurements on the first six samples in June data should be reflected in the 

surrogate data set. However, the tests included slugs made of depleted uranium, which would 

have produced the same airborne mass concentrations (e.g., μg/m3) as natural uranium, but lower 

activity concentrations. Since, according to EECAP (2012), Tocco received 5,600 lb of depleted 

uranium and 2,000 lb of natural uranium, and since the February tests were of natural uranium, 

we made the claimant-favorable assumption that all the June data are from depleted uranium. 

We recalculated these activity concentrations, multiplying each value by 1.887, the ratio of 

specific activities of natural to depleted uranium, and substituted the revised values in the 

surrogate data set. 

3.4 Feed Materials Production Center, Fernald, Ohio 

According to Ross et al. (1963), 

Air dust samples were collected during the week of August 19, 1963, for the 

purpose of evaluating the air dust levels generated during the reduction of 1.25% 

enriched UF4 to uranium metal. During the sample period complete ventilation 

for the reduction area was provided by G37-5011 dust collector. The primary 

duct to the breakout enclosure was closed to allow maximum ventilation at the 

breakout table. 

Ross et al. (1963) tabulated 17 sets of BZ samples—the concentrations for each set were 

presented as high, low, and average, with no indication of how many samples comprised each 

set. Only three of these data sets referred to uranium metal: those labeled “breaking out derby,” 

“cleaning derby,” and “removing derby from breakout table.” Allen (2012b) included these data 

in the surrogate data set, utilizing the high, low, and average values as if they represented three 

individual measurements. 

We have several objections to the use of these data. First, the operations were performed with 

maximum ventilation, which does not correspond to working conditions in the GSI betatron 

shooting room. Second, the uranium is enriched, while most if not all the uranium handled at 

GSI was natural. Third, the operation “cleaning derby” implies some disturbance of the surface 

that could have been more aggressive than merely handling and transferring uranium metal. 

Fourth, we do not agree with assigning the average value as a third datum. 

Some of these issues could be resolved by adjusting the reported values. The measured activity 

of the 1.25% enriched uranium could be adjusted to correspond to natural uranium. The 

operation “cleaning derby” could be omitted, leaving two sets of data. Since most of the BZ data 

at other sites surveyed by NLO personnel consist of three sets of readings over a short time span 

at a given location, we could use the three reported values—high, low, and average—to calculate 
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the presumed third value and enter it, along with the high and low values, in the data set. 

However, we do not know how to account for the maximum ventilation, which does not 

represent conditions at GSI. We therefore excluded the Fernald data from the revised surrogate 

data set. 

3.5 Weldon Spring 

3.5.1 Dingot Handling 

Reyland (1960) described a dust study performed on a dingot lathe at the Weldon Spring Plant. 

Two BZ samples were collected during the removal and installation of a dingot on the lathe by 

means of an overhead hoist; this operation is similar to the dingot handling at GSI. Allen 

(2012b) appropriately included these readings in the surrogate data set. 

“Uranium Dust Study . . .” (1961) describes the operation of the dingot machining station that 

was located at the Weldon Spring Plant. “A dingot grab and bridge crane combination is used 

for moving the dingots from the storage area to the lathes. The dingot is centered on the lathe 

table and secured in the chuck.” These operations were performed before a fume hood was 

moved into place, so there was presumably little or no forced ventilation during this time. Table 

I, “Measured Uranium Dust Concentrations at the Dingot Machining Station – 301 Metal Plant,” 

includes concentrations measured during “installation and removal of dingot in lathe.” The 

measurements are listed as 2.1–3.0 × 10-11 μCi/cm3

; the table also lists the average concentration 

as 76 μg/m3. A footnote lists the assumed conversion factor of 3 × 106 g/Ci of natural uranium.1

Allen (2012b) included these measurements in the surrogate data base. He apparently divided 

the average concentration—76 μg/m3—listed in the table by the conversion factor to derive the 

average value of 2.533 μCi/cm3, and converted all three values (the average, and the low and 

high ends of the range) to dpm/m3

. We observe that dividing the average dust concentration by 

the conversion factor and rounding to one decimal place yields 2.5 × 10-11 μCi/cm3, which is the 

rounded average of the range of readings. It would appear strange for the report to list a range in 

μCi/cm3 and an average in μg/m3—it is more likely that the author simply averaged two readings 

and converted to μg. We therefore believe it is not correct to use the average as a third value and 

have eliminated it from the revised surrogate data set. We retained the high and low values in 

the surrogate data set. 

3.5.2 Core Outgassing 

“Core Outgassing” (1960) describes the heating of uranium slugs in a vacuum furnace. The α air 

activity concentrations include only one BZ sample measured before the slugs were heated in the 

furnace. The other BZ samples were taken after the furnace was unsealed and the operator was 

exposed to the hot slugs. Unlike the data selected from other sources, Allen (2012b) selected 

three general air samples from this document for inclusion in the surrogate data set. These data 

are inconsistent with the rest of the surrogate data set. We excluded them from the revised data 

set and added the single BZ sample in their place. 

1

 The currently accepted value is 4.6 × 106 g/Ci.
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3.6 Mallinckrodt2

Mallinckrodt (1957) lists α air concentration measurements during dingot machining, including 

three BZ samples collected while the worker was setting up the dingot for machining on a lathe. 

Allen (2012b) appropriately included these results in the surrogate data set. 

3.7 Results and Conclusions 

Table 1 presents a summary of our analyses of data from the individual work sites. All activity 

concentrations listed by Allen (2012b, Attachment 1) are included. Data on measurements that 

we excluded from our revised surrogate data set are listed in blue and struck out. Data that we 

added are listed in red and underlined. There were 37 concentrations in Allen’s original data set; 

our revised surrogate data set includes 28 readings. We have performed a statistical analysis of 

Allen’s data, using the regression of order statistics (ROS) method to fit the data to a lognormal 

distribution, and confirmed the upper 95th percentile value of 104 dpm/m3

. The best fit of these 

data, which include six nondetect readings, yields a value of R2 = .8781. A similar analysis, 

based on the best fit of our revised data set to a lognormal distribution, results in a 95th 

percentile of 66.4 dpm/m3

. Our adjusted data set, including eight nondetect readings and one 

low-value outlier that is not part of the curve fit, yields R2

 = .946. The goodness of fit of the 

revised data is further confirmed in that the empirical 95th percentile value, calculated by a 

nonparametric analysis, is 66.9 dpm/m3, which is within 1% of the previous value. This method 

makes no assumption about the form of the underlying distribution. The details of the analyses 

are presented in Appendix A. 

The revised data set thus provides a better fit to a lognormal distribution and more closely 

satisfies the surrogate data criteria, as discussed below. However, Allen’s (2012b) data yield a 

more claimant-favorable surrogate value. 

4 Evaluation of Surrogate Data 

The ABRWH Work Group on Use of Surrogate Data (2010) issued five “criteria that need to be 

considered in determining whether the specific use of surrogate data for individual dose 

reconstruction is scientifically sound and appropriate for that particular application.” We have 

applied these criteria in reviewing the use of Allen’s (2012b) data and our own revised data set to 

derive surrogates for the uranium handling operations at GSI. Following the statement of each 

criterion is an evaluation of how well the use of these surrogate data conforms to that criterion.

2

 Allen (2012b) attributed these data to Weldon Spring while in fact, Plant 7W, where the data were collected, 

was located at the Mallinckrodt Chemical Works in St. Louis (Westbrook and Bloom 2007).
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Table 1. Airborne Activity Samplesa

Site Form α activity 

(dpm/m3

) Reference Description 

 LeBlond billets 9 Allen 2012b 

 LeBlond billets ndb Allen 2012b 

 LeBlond billets nd Allen 2012b 

Operator hooking hoist to billet and 

placing billet into position on machine 

 LeBlond billets 15 Allen 2012b 

 LeBlond billets nd Allen 2012b 

 LeBlond billets nd Allen 2012b 

Operator removing billet from machine 

after billet had been bored and placing 

billet on scale 

 LeBlond billets nd Workum 1961 

 LeBlond billets nd Workum 1961 

 LeBlond billets 15 Workum 1961 

 LeBlond billets 9 Workum 1961 

 LeBlond billets 9 Workum 1961 

 LeBlond billets 1 Workum 1961 

Operator operating controls of 

machine. No visible dust or fumes – 

oil splatters near end of operation 

 Chambersburg slugs 24 Allen 2012b 

 Chambersburg slugs 5 Allen 2012b 

 Chambersburg slugs 28 Allen 2012b 

Operator working safety control on 

impactor, which is located 5' west of 

impactor 

 Tocco slugs 53 Allen 2012b 

 Tocco slugs 22 Allen 2012b 

8′′ normal slugs – no ventilation: 

Loading uranium slugs on run-in table

5 Allen 2012b Tocco slugs 9.44 Adjusted for DU 

37 Allen 2012b Tocco slugs 69.83 Adjusted for DU 

5 Allen 2012b Tocco slugs 9.44 Adjusted for DU 

Loading slugs at loading tray – heating

24 Allen 2012b Tocco slugs 45.30 Adjusted for DU 

 Tocco slugs nd Allen 2012b 

19 Allen 2012b Tocco slugs 35.86 Adjusted for DU 

Loading slugs – no heat 

 Fernald derby 45 Allen 2012b 

 Fernald derby 50 Allen 2012b 

 Fernald derby 34 Allen 2012b 

Breaking out derby 

 Fernald derby 60 Allen 2012b 

 Fernald derby 74 Allen 2012b 

 Fernald derby 47 Allen 2012b 

Cleaning derby 

 Fernald derby 88 Allen 2012b 

 Fernald derby 11 Allen 2012b 

 Fernald derby 60 Allen 2012b 

Removing derby from breakout table 

 Weldon Spring dingots 24 Allen 2012b 

 Weldon Spring dingots 21 Allen 2012b Removing and installing dingot 

 Weldon Spring dingots 56.24 Allen 2012b Spurious data based on average 
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NOTICE:

Table 1 (continued) 

Site Form α activity 

(dpm/m3

) Reference Description 

 Weldon Spring dingots 66.6 Allen 2012b 

 Weldon Spring dingots 46.62 Allen 2012b 

Installation and removal of dingot in 

lathe 

 Weldon Spring slugs 25 Allen 2012b 

 Weldon Spring slugs 25 Allen 2012b 

 Weldon Spring slugs 25 Allen 2012b 

General air samples, not breathing 

zone 

 Weldon Spring slugs 23 “Core Outgassing” 1960 Positioning & bolting to flange (BZ) 

 Weldon Springc dingots 11.8 Allen 2012b 

 Weldon Springc dingots nd Allen 2012b 

 Weldon Springc

 dingots 23.7 Allen 2012b 

Setting up dingot 

Source: Allen (2012b, Attachment 1)

a Red text and underlined values indicate data added in the present review; blue text and struck-out values indicate data 

excluded by present review

b nd = not detected

c As listed by Allen (2012b)—operations took place at the Mallinckrodt Chemical Works in St. Louis

4.1 Criterion 1: Hierarchy of Data 

It should be assumed that the usual hierarchy of data would apply to dose 

reconstructions for that site (individual worker monitoring data followed by coworker data followed by workplace monitoring data such as area sampling 

followed by process and source term data). This hierarchy should be considered 

when evaluating the potential use of surrogate data. Surrogate data should only 

be used to replace data if the surrogate data have some distinct advantages over 

the available data and then only after the appropriate adjustments have been made 

to reflect the uncertainty inherent in this substitution 

There are no monitoring data relating to uranium intakes at GSI. The only data relating to 

uranium contamination are from FUSRAP surveys of the Old Betatron Building performed in 

1989 and 1993. The TBD-6000 work group concluded that these data cannot be used to 

calculate airborne uranium concentrations during the operational and residual periods because of 

the long time that elapsed before the surveys were performed and because of reports that the 

building was cleaned following the operational period. Thus, we conclude that the use of 

surrogate data conforms to the hierarchy of data. 

We next need to determine if appropriate adjustments have been made to the surrogate data as it 

was applied to GSI. As discussed in preceding sections of this review, the surrogate airborne 

activity concentrations were derived by calculating the 95th percentiles of the assumed 

lognormal distributions, which produces a claimant-favorable result. This constitutes 

“appropriate adjustments” to the surrogate data. We find that Criterion 1 is satisfied both by 

Allen’s (2012b) data, and by the revised data set in the present review. 
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4.2 Criterion 2: Exclusivity Constraints 

[In situations where] there are no or very little monitoring data available . . . the 

use of the surrogate data as the basis for individual dose reconstruction would 

need to be stringently justified. This judgment needs to take into account not only 

the amount of surrogate data being relied on relative to data from the site but also 

the quality and completeness of that surrogate data.3

As stated previously, there are no monitoring data on uranium intakes at GSI. NIOSH searched 

the site research data base (SRDB) and found seven sites or operations that appeared to include 

data on airborne uranium concentrations that resulted from the handling of cold uranium metal. 

As discussed earlier, we found that two of these data sets, as well as some individual values from 

the remaining five operations, do not constitute suitable surrogate data. However, we found that 

21 measurements did conform to the requirements for surrogate data;4

 in addition, we found 

seven more measurements at these same work sites that are suitable additions to the surrogate 

data set. We believe that the use of these data is, in fact, adequately justified, and that 

Criterion 2 is satisfied. 

4.3 Criterion 3: Site or Process Similarities 

One of the key criteria for judging the appropriateness of the use of surrogate data 

would be the similarities between the site (or sites) where the data were generated 

and the site where the surrogate data are being utilized. The application of any 

surrogate data to an individual dose reconstruction at a site should include a 

careful review of the rationale for utilizing that source of data. Factors that could 

be considered include, but are not limited to, similarity of the production 

processes, presence or absence of conditions that might affect exposure, and 

monitoring methods employed at the site(s). The potential availability of other 

sources of surrogate data needs to be considered and the selection of the surrogate 

data used for dose reconstruction justified. Some of the questions to be 

considered where appropriate are: 

 Are there other sources of surrogate data that were not used? 

 Do these other potential sources contradict or undermine the application of the 

data from the selected site? 

 Are there adequate data characterizing the site being used that would help support 

its application to other sites? 

 Do the surrogate data reflect the type of operations and work practices in use at 

the facilities in question? 

3

 Only the relevant text from Criterion 2 is quoted here. 

4

 These include five values that we adjusted to reflect activity concentrations that may have been generated by 

the handling of depleted uranium. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Surrogate data should not be used if the equivalence of working conditions, 

source terms, and processes of the surrogate facility to the one for which dose 

reconstructions are being done cannot be established with reasonable scientific or 

technical certainty as outlined here. 

Six of the measurements in our revised data set were made while the operator was handling 

uranium billets, while six more (that we added) were made while the operator was operating the 

controls in the vicinity of a boring machine. Since the boring did not generate any airborne 

activity, he can be presumed to be exposed to residual dust from the handling operation. Seven 

other airborne concentrations were from the handling of dingots. Since both billets and dingots 

can be assumed to have been radiographed at GSI, these data are directly relevant to GSI 

operations. Nine other measurements were during the handling of uranium slugs. While the 

slugs do not exactly conform to uranium objects known to have been radiographed at GSI, they 

do fall into the general category of handling cold uranium metal, and are thus suitably included 

in the data. 

In response to the first bullet item under Criterion 3, we are satisfied that NIOSH explored the 

available data and included all reasonable sources of surrogate data; bullet item 2 is thus moot. 

Items 3 and 4 are likewise satisfied by the descriptions of site operations that accompany the 

adopted data. 

We observe that the data cover cold uranium handling operations involving slugs, billets, and 

dingots. The range of the shapes and sizes adequately encompasses the uranium shapes handled 

at GSI. The materials handling processes for moving large metal shapes are not unique to GSI or 

to the surrogate data sites. They are representative of general heavy industry practices. We thus 

conclude that the surrogate data basically conform to Criterion 3. 

4.4 Criterion 4: Temporal Considerations 

Consideration also needs to be given to the period in question, since working 

conditions and processes varied in different periods. Surrogate data should 

belong in the same general period as the period for which doses are sought to be 

reconstructed unless it can be demonstrated that the working conditions, 

procedures, monitoring methods, and (perhaps) legal requirements were 

comparable to the period in question. 

The surrogate data span the years 1956–1968, which overlap most of the 1953–1966 period of 

operations at GSI. There is no reason to believe that work practices at GSI in 1953–1955 

differed from those in later years, since we are not aware of any efforts to mitigate the generation 

of uranium dust nor the workers’ exposure to such dust during the later years. 

4.5 Criterion 5: Plausibility 

The manner in which the surrogate data are to be used must be “plausible” with 

regard to the reasonableness of the assumptions made. The plausibility 

determination should address issues of: 
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 Scientific plausibility. Are the assumed models (e.g., bioassay, 

concentration gradients) scientifically appropriate? Have the models been 

validated (where feasible) using actual monitoring data collected in a 

similar situation? 

 Workplace plausibility. Are the assumed processes and procedures 

(including monitoring) plausible for the facility in question? Have all of 

the factors that could significantly impact exposure been taken into 

account? Is adequate information available about the facility in order to 

be able to make a fair assessment? 

The measurements at the various sites were done in the course of safety inspections by AEC 

contractor personnel and are presumed to have conformed to applicable health and safety 

standards. We assume that they represent the same level of scientific validity as any other health 

physics monitoring of that era. We believe that these data satisfy the criterion of scientific 

plausibility. 

Dust generation from the movement of heavy metal shapes and materials is not expected to be 

strongly site specific. Lifting equipment is generally selected on the basis of the loads to be 

handled. Thus, use of data from lifting and handling at surrogate sites is a fair representation of 

operations that occurred at GSI. This is especially true when the same shapes (e.g., dingots) 

were handled at both GSI and surrogate sites. We believe that use of the proposed surrogate data 

is consistent with the plausibility criterion. 

5 Conclusion 

We have reviewed the data on airborne uranium activity concentrations resulting from the 

handling and transport of cold uranium metal presented by Allen (2012b). We find that, with 

appropriate adjustments and revisions, such data yield a suitable surrogate for the airborne 

uranium activity concentrations resulting from the handling and transport of uranium at GSI. 

The revised and adjusted data satisfy the five Board criteria for the use of surrogate data and are 

statistically robust, the ROS method and the nonparametric empirical method yielding almost 

identical values. 
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References

ABRWH Work Group on Use of Surrogate Data. 2010. “Criteria for the Use of Surrogate Data,” 

Final Draft (May 14, 2010). http://www.cdc.gov/niosh/ocas/pdfs/abrwh/proc/abrwh-proc-sdr0.pdf. 

Allen, D. 2012a. “Use of Surrogate Data at GSI: Response to SC&A Review Dated July 16, 

2012.” http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-gsisd-0812.pdf

Allen, D. 2012b. “Evaluation of Additional Air Sample Data Applicable to GSI.” 

http://www.cdc.gov/niosh/ocas/pdfs/dps/dc-gsiasd-1112.pdf

Allen, D., and S. Glover. 2007. “Site Profiles for Atomic Weapons Employers That Worked 

Uranium and Thorium Metals - Appendix BB: General Steel Industries,” Battelle-TBD-6000, 

Appendix BB, Rev. 0. http://www.cdc.gov/niosh/ocas/pdfs/tbd/b-6000-apbb-r0.pdf. 

Anigstein, R. 2012. “Review of the Use of Surrogate Data for Estimating Intakes of Uranium at 

General Steel Industries.” http://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-gsisd-r0.pdf

“Core Outgassing.” 1960. SRDB Ref. ID: 14956. 

Department of Energy (U.S.), Office of Environmental Management, Depleted Uranium 

Hexafluoride Management Program (DOE). 2001. “Characteristics of Uranium and Its 

Compounds.” http://web.ead.anl.gov/uranium/pdf/UraniumCharacteristicsFS.PDF

Energy Employees Claimant Assistance Project (EECAP). 2012. “Tocco Induction Heating 

Division, Cleveland Ohio.” http://www.eecap.org/Covered_Facilities/Ohio/Tocco.htm 

Mallinckrodt Chemical Works, Uranium Division. 1957. “Dust and Radiation Study of the 

Machining of Dingot and Ingot Metal at Plant 7W.” SRDB Ref. ID: 17254. 

National Lead Company of Ohio (NLO). 1957. “Analytical Data Sheet.” SRDB Ref. ID: 43252. 

National Lead Company of Ohio (NLO). 1968. “Analytical Data Sheet.” SRDB Ref. ID: 98533. 

Reyland, W. L. 1960. “Dust Study of Dingot Lathe in Building 301,” memo to W. L. Utnage, 

Mallinckrodt Chemical Works, Uranium Division, Weldon Spring (December 14, 1960) SRDB 

Ref. ID: 12363, pp. 75–78. 

Ross, K. L., R. L. Rube, and R. C. Wissman. 1963. “Air Dust Evaluation of Metal Reduction – 

Pilot Plant.” SRDB Ref. ID: 34390. 

Rube, R. L. “Trip Report to Chambersburg Engineering Co., Chambersburg, Pennsylvania, on 

March 20 & 21, 1957.” National Lead Company of Ohio Memorandum to J. A. Quigley, M.D. 

SRDB Ref. ID: 10048. 
Effective Date: 

November 25, 2012 

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0 – Draft 

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Review of New Surrogate Data for GSI 

Page No. 

Page 15 of 18 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

“Uranium Dust Study for Dingot Machining Station – 301.” 1961. SRDB Ref. ID: 12363, pp. 

19–23. 

Westbrook, J. L., and C. W. Bloom. 2007. “Basis for Development of an Exposure Matrix for the 

Mallinckrodt Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St. 

Louis, Missouri,” ORAUT-TKBS-0005, Rev. 02. 

http://www.cdc.gov/niosh/ocas/pdfs/tbd/mallink-r2.pdf

Workum, A. D. 1961. “Trip Report to LeBlond Machine Tool Company, Cincinnati, Ohio, on 

January 16 to 20, 1961.” National Lead Company of Ohio Memorandum to J. A. Quigley, M.D. 

SRDB Ref. ID: 10634. 
Effective Date: 

November 25, 2012 

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0 – Draft 

Document Description: White Paper: 

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Page No. 

Page 16 of 18 

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Appendix A 

 Regression Analyses of Surrogate Data

A.1 Regression Analysis of Allen’s (2012b) Data 

The regression of order statistics (ROS) method was used to fit a lognormal distribution to 

Allen’s (2012b) data, including the six nondetect values. A plot of the logarithms of the data 

versus the normal score for each observation is shown in Figure A.1. (The figure omits six 

nondetect data points included in the distribution.) The plot also contains a regression line which 

best fits the plotted data points. The slope and intercept of the regression line are also shown on 

the figure. Although the data approximately follow the regression line, the data points are below 

the regression line at both ends of the plot, while they are above the regression line in the middle 

of the plot. The value of R2 = .8781 indicates a reasonable fit to a lognormal distribution. 

y = 0.9635x + 3.0562

R2

 = 0.8781

1

1.5

2

2.5

3

3.5

4

4.5

5

5.5

-1 -0.5 0 0.5 1 1.5 2 2.5

z-score

 ln (X)

Figure A.1. Lognormal Distribution of NIOSH Data, Using Regression on Order Statistics 

The slope and intercept of the regression line are used as estimates of the parameters of a 

lognormal distribution. The characteristics of this lognormal distribution are shown in 

Table A.1. The estimate of the 95th percentile confirms the result of 104 dpm/m3

 obtained by 

Allen (2012b). At the right of the plot in Figure A.1, the highest five data points fall below the 

regression line, indicating that the data distribution has a smaller right-hand tail than would be 

expected from a lognormal distribution. Hence the estimate of the 95th percentile obtained using 

the ROS method exceeds the empirical 95th percentile of 83.1 dpm/m3, which lies between two 

sample values located at 74 and 88 dpm/m3. The ROS estimate of 104 dpm/m3 for the 95th 

percentile appears to be claimant favorable, as it exceeds the empirical 95th percentile of the 

distribution by approximately 20%.
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NOTICE:

 Table A.1. Lognormal Distribution Parameters Estimated using ROS Method 

Surrogate Data Set Parameter 

NIOSHa Revisedb Adjustedc

Intercept (μ) 3.0562 2.34 2.5387 

Slope (σ) 0.9635 1.2155 1.0076 

R2 0.8781 0.7811 0.946 

Geometric mean 

(dpm/m3

) 21.25 10.38 12.66 

GSD 2.62 3.37 2.74 

95th %ile (dpm/m3

) 103.66 76.67 66.43 

a Allen 2012b

b Present analysis—all data points

c Present analysis—curve fit omits lowest data point

A.2 Regression Analysis of Revised Data 

Figure A.2 shows a plot of our revised data set. The value of R2 = .7811 indicates a poorer fit to 

the regression line for the lognormal distribution. (The figure omits eight nondetect data points 

included in the distribution.) The characteristics of this distribution are shown in Table A.1. At 

the right of the plot in Figure A.2, the highest two data points fall below the regression line, 

indicating that the distribution has a smaller right-hand tail than would be expected from a 

lognormal distribution. Hence the estimate of the 95th percentile obtained using the ROS 

method, ~77 dpm/m3, exceeds the empirical 95th percentile of 66.92 dpm/m3, which lies 

between two sample values located at 66.6 and 69.83 dpm/m3, by approximately 13%. 

A.3 Regression Analysis of Adjusted Revised Data 

The poor fit of the data in Figure A.2 is due to a single datum of 1 dpm/m3, which appears to be 

an outlier. If we retain it in the data set but exclude it from the curve fit, we obtain the plot 

shown in Figure A.3. The characteristics of this distribution are shown in Table A.1. This plot 

has an R2

 = .946, which indicates a very good fit to a lognormal distribution. Hence the estimate 

of the 95th percentile obtained using the ROS method, 66.43 dpm/m3

, is within 1% of the 

empirical 95th percentile of 66.92 dpm/m3

. 
Effective Date: 

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y = 1.2155x + 2.34

R2

 = 0.7811

0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

5

-1 -0.5 0 0.5 1 1.5 2 2

z-score

ln (X)

.5

Figure A.2. Lognormal Distribution of Revised Data, Using Regression on Order Statistics 

y = 1.0076x + 2.5387

R2

 = 0.946

1.5

2

2.5

3

3.5

4

4.5

-0.5 0 0.5 1 1.5 2 2.5

z-score

 ln (X)

Figure A.3. Lognormal Distribution of Adjusted Data Using Regression on Order Statistics